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White paper for Executives, boards & advisory boards

The Training You Cannot Delegate.

NIS2, the German critical-infrastructure act and the EU AI Act side by side: what each demands of the leadership level, what stays delegable, and what has to be on file.

The problem this is about

The trained reflex for every new obligation is to appoint someone, hand over the topic and tick it off. With these three laws it fails, because the person who has to be trained is the one who usually delegates.

Section 38(3) BSIG has required regular management training since 6 December 2025; the critical-infrastructure act has additionally required proof on request since 17 March 2026. Breach triggers liability under company law: down to private assets in a damage case.

What is inside

  • The three laws side by side: trigger, start date, addressee and fine ranges in one overview
  • The dividing line: what you may hand over, and what stays with you
  • Four components of evidence that holds, who by name, at what cadence, on what, with what result
  • Why an attendance confirmation reads differently from a passed assessment when it matters

For executives and board members who want to know what they personally owe, before a regulator, an insurer or a court asks.

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  • 11 pages
  • PDF
  • As of August 2026

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All papers provide general information and are not legal advice.

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